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CASH 
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DISTRICT ATTORNEY

 

 

 

 

 

SUPERIOR COURT or CALIFORNIA sumo
COU, mam/m assassins?
. (Indie) FEB @0155
THE PEOPLE OF THE STATE OF CALIFORNIA,  212/41}; an. aide; 
e/ .
Plaintiff,  NO. 5 Keg
v. FELONY COMPLAINT .31..
GU
JOHN DAVID YODER 
a: 
easterlies 201504272 
Defendant.

COUNT 1 


The undersigned, un der penalty ofperjuryupon information and belief, declares: That the above nam ed
defendant committedaviolation of Penal Code section 2.69, subdivision subsection (4), a felony, in that on
or about January 1, 2012, through and including January 31, 2015, in the County ofRiverside, State of
California, he did wilfully, unlawfully, and lewdly commit a violation of subsection (2) or t, 3) of subdivision 
or subdivision of Penal Code section 288:1, ORAL COFULATWN, by force, violence, duress, menace and fear
of immediate andunlaw?ilbodily injury, upon JOHN 1, a child who Vim under 14 years of age and seven
or ore years younger than the defendant.

.1 COUNT 2 i

That the above named defendant eommitteda violation of Penal Code section 23 6.1, subdivision a
felony, in that on or about January .1, 2012, through and including January 31, 2015, in the County of Riverside,
State of California, he did will?slly and unlawfully cause, induce, and persuade, and attempt to cause, induce
and persuade GEN DOE 1, a minor at the time of the commission of the offense, to engage in a comm ereial

sex act, with the intent to attest and maintain a violation of Penal Code sections 266, 26611. 266i, 266}. 257.
311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518.

COUNT 3

That the above named defendant eommitteda violation of Penal Code section 182, subdivision 
subsection (1), a felony, in that on or about January 1, 2012, through and including January 31, 2015, in the
County of Riverside, State of Califomia, he did wilfully and unlawfully conspire together and with WILLIAM
THOMPSON, to comm it the crime THE USE OF MINORS TO PERFORM 
SEX ACTS, in violation of Penal Code section 311.403), 3. felony, and that pursuant to and for the purpose of
carrying out the sheets and purposes of the aforesaid conspiracy, the said defendants thereafter committed the
following overt act and acts stand in the County of Riverside:

OVERT ACT NO. 1

BE CONSPIRED WITH WILLIAM THOMPOSON TO LURE THE UNDER AGE JOHN DOES TO
PERFORM SEX ACTS

COURT ORIGINAL

 

 

 

 

 

 

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COUNT 4

That?the above named defendant committedaviolation of Penal Code section 288, subdivision a
felony, in that on or about January 1; 2012, through'and including January 31, 2015, in the Con 'ty of Riverside,
State of California, he did wilfully, unlawfully, and lewdly commit allewd and laseivions act origin arid with the
body and certain parts and members thereof of JOHN DOE 1, a child under the age? of fourteen years, with the
Etentgfalr?cigsing, appealing to, and passions, and semal desires fifths said defendant and

SM '1 . 


semi/V? 

That the above 11am ed defendant oommitteda violation of Penal code section 32., a felony, in that on or
about January 1, 2012 through and including January 31,. 20 15, in the County of Riverside, State of California,
he did Wil?illy and unlawfully,having knowledge that the crime of child pom, a felony, in violation of section
311 of the Penal Code of the. State of Californiahad been cornmittvedby WILLIAM did harbor,
conceal and aid said IHOMPSON, with the intent that?he miglit'avoid and escape'from arrest, trial,

-
um; PBIHEULUEHL 5211B ik?ll?ly. 

atnasr?stnw

Information contained in the reports being distributedas discovery in this case may contain confidential

information protected by Marsy?s Law andthe amendments to the California Constitution'geotion 28. Any 
victim(s) in any above referenced eharge(s) is entitledto be free ?ow intimidation,harassxn ant, and abuse. It is
unlawful for defendant(s), defense counsel, and-any other person magen- behalf of the defendant(s) to use any
information containedin the reports to locate or harass any victim(s) or the family or to disclose any
information that-is otherwise privileged and confidential by law: Additionally, itis a misdemeanor violation of
CaliforniaPenal Code 1054.2a(3) to disclose the address and telephone number ofa victim or Witness to a
defendant, defendmit?s family member or anyone else. Note exceptions in California-Penal Code 
and (2). - 1

I declare under?penalty of perjury upon information andlbeliefnnderthe laws of the State of California

that the foregoing is true and correct.
i ?ag

Gomplainant

Dated: February 3, 2015





COURT